1. INTRODUCTION

  1.1 The Agency welcomes the opportunity to submit comments to the Select Committee in respect of the Government's White Paper, A New Deal for Transport: Better for Everyone. These comments are set out below under the following headings:

—  General comments.

—  Proposals endorsed by the Agency.

—  Matters giving rise to Agency concern.

—  Options proposed by the Agency but omitted from the White Paper.

2. GENERAL COMMENTS

  2.1 In November 1997, the Agency submitted its response to the Government's consultation paper "Developing an Integrated Transport Policy". A copy of that response is attached. (Appendix 1).

  2.2 Towards the end of 1997 the DETR requested advice from the Agency regarding the potential impact on the environment of the road schemes included in its short-term programme and, in conjunction with other relevant government agencies, to advise on the development of a New Appraisal Framework. The Agency recommended and devised a risk-based approach which was then used to assess the potential impacts of road schemes on the water environment. This approach has the potential to be adapted to appraise multi-modal transport schemes and the Agency is now discussing this possibility with the DETR. The Agency also believes that there needs to be considerable public involvement in the application of the New Appraisal Framework.

  2.3 The White Paper states that the new Commission for Integrated Transport "will bring together transport users, the private sector, local authorities and others to make recommendations to Ministers". The Agency considers it can make a significant contribution to the work of the Commission by providing expert advice on relevant environmental issues.

3. PROPOSALS ENDORSED BY THE AGENCY

  3.1 The Agency welcomes the Government's commitment to giving transport the highest possible priority, and the emphasis given to the importance of achieving sustainable development. Recognition of the fact that the way forward is through an integrated transport policy is endorsed by the Agency, in particular the commitment to setting out a framework which, among other environmental objectives, "ensures that the environmental impacts are taken fully into account in investment decisions and in the price of transport".

  3.2 Recognition of the importance of introducing measures to reduce rural isolation and social exclusion is also welcomed by the Agency, particularly in respect of rural communities. An effective level of public transport infrastructure in rural areas will clearly contribute towards improving the social and economic wellbeing of rural communities, but this needs to be a sustainable measure and should not be undertaken at the expense of the environment.

  3.3 The construction of new roads brings substantially increased risk to the environment, especially where the route impinges on environmentally sensitive areas. The Agency therefore welcomes and supports the emphasis which the White Paper places on maintaining existing roads rather than building new ones, and that it sets out to reduce the growth of road traffic, and encourages the use of alternative modes of transport by seeking to secure an integrated system through national, regional and local strategies.

  3.4 The maintenance of existing roads may, in most instances, have less of an impact on the environment than the construction of new roads. Nevertheless, all maintenance proposals must have regard to the potential risk of impact on the local environment and include appropriate mitigation and enhancement measures. The key to the success of this measure will be the introduction of pollution control devices on existing roads and their effective maintenance by the Highways Agency and others.

  3.5 The proposed revision of planning guidance, together with an increased emphasis on urban design, will provide an essential opportunity to ensure that the issues relating to transport and the environment are taken into account at the planning stage. This is particularly important in respect of determining the locations for major growth and travel generating uses. Similarly, the integration of local transport plans and development plans will afford greater opportunities to safeguard the natural environment.

  3.6 The initiatives to reduce congestion by allowing local authorities to charge road users are welcomed, as are the proposals for charging users of motorways and trunk roads. These measures could be important for achieving an appropriate balance between the demand for transport and the provision of transport infrastructure which does not incur excessive environmental costs. The development and monitoring of pilot charging schemes should be introduced as soon as possible.

4. MATTERS GIVING RISE TO AGENCY CONCERNS

  4.1 Whilst the integration of local transport plans and development plans is welcomed, this will only result in positive benefits if the lifespan and timescales for implementation and review of both documents are closely co-ordinated. Development plans are currently at different stages of preparation and the timescale involved in reviewing such plans varies considerably. The review of planning guidance will need to address the co-ordination of local transport plans and development plans.

  4.2 The proposed increased use of waterways as a means of transport is recognised. It is however important that any such increase is not at the expense of environmental considerations; for example, the reference under Thames 2000 to "a programme of infrastructure works to create up to 10 piers at key locations on the river, modernise existing piers and improve linkages with other public transport" must respect the sensitivity of the tidal foreshore areas.

  4.3 Although the technological solutions identified in the White Paper will contribute towards improving the current transport situation, it is nevertheless necessary to recognise that behavioural change is also needed. The relationship between attitudes and behaviours is complex and poorly understood with respect to environmental issues. The Agency therefore urges that greater consideration be given to this complex aspect, particularly to the identification of measures that can most effectively succeed in altering actual behaviour and reducing road travel.

5. OPTIONS PROPOSED BY THE AGENCY BUT OMITTED FROM THE WHITE PAPER

  5.1 Statements on the environmental benefits and rationale for using a variety of economic instruments are welcomed. Such instruments can play a major part in achieving environmental objectives concerning transport. Unfortunately, the White Paper does not set out the scale, nature, significance and costs of the environmental damage that is caused by each transport option. Environmental damage caused by individual transport users must form part of any consideration of fiscal and other control measures if they are to be accepted, implemented, and acted upon effectively. The Agency therefore recommends that indicative estimates of the environmental damage caused by each transport option be published at the earliest opportunity. The Agency is willing to help in this process.

  5.2 The White Paper does not specify the extent to which the projected growth in traffic presents an increasing challenge to achieving environmental targets for the emission of pollutants from motor vehicles. The Agency therefore welcomes the statements describing the important role which local authorities will have in the new system of Local Air Quality Management for achieving air quality targets. As a consultee in the process, the Agency looks forward to contributing to the development of action plans for each air quality management area.

  5.3 The Agency suggests that the current review of the National Air Quality Strategy should detail the specific measures to be taken, and highlight any uncertainties concerning their effectiveness and the extent to which these could jeopardise achievement of the targets. It is also recommended that the DETR establishes a system for monitoring and regularly reporting the progress made towards achieving targets.

  5.4 With regard to the stated aim to reduce greenhouse gas and CO₂ emissions in the UK, the Agency looks forward to seeing the consultation paper on options for meeting targets. It considers that the consultation paper should identify and analyse in detail the likely effect of each of the various measures in the White Paper and, more importantly, their effectiveness. The paper should also set out what additional measures will need to be considered if the proposed measures do not turn out to be as effective as originally envisaged; for example, if there is not in practice a significant change in attitude to road use.

6. SUMMARY

  6.1 The Agency welcomes the Government's White Paper as a way forward in the pursuit of achieving sustainable development, and wishes to work closely with the Government, the new Commission for Integrated Transport, the Regional Development Agencies, and local authorities in developing policy and monitoring progress. The Agency already works closely with local authorities as a statutory consultee on land use planning matters, and during the preparation and implementation of Local Environment Agency Plans (LEAPS). These activities are particularly relevant to the issues contained in the White Paper.

  6.2 Many of the environmental impacts of transport options affect the way in which the Agency is able to discharge its statutory obligations, and its ability to maximise its contribution to sustainable development.